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(a) General ruleOriginal issue discount on any tax-exempt obligation shall be treated as accruing—
(1) for purposes of section 163, in the manner provided by section 1272(a) (determined without regard to
For purposes of this part and of sections 164(a) and 275(a), the term "income, war profits, and excess profits taxes" shall include a tax paid in lieu of a tax on income, war profits, or excess profits otherwise generally imposed by any foreign country or by any possession of the United States.
Any person who—
(1) uses denatured distilled spirits withdrawn free of tax under section 5214(a)(1) in the manufacture of any medicinal preparation or flavoring extract in violation of the provisions of section 5273(b)(1) or
(a) In general. If any person willfully alters, or attempts to alter, the strength or composition of any dye or marking done pursuant to §48.4082-1 in any dyed fuel, then section 6715(a)(3) provides that such person shall pay a penalty in addition to any tax. The penalty imposed by section 6715(a)(3) will not apply in the
(a) Failure to furnish copy to taxpayerAny person who is a tax return preparer with respect to any return or claim for refund who fails to comply with section 6107(a) with respect to such return or claim shall pay a penalty of $50 for such failure, unless it is shown that such failure is due to reasonable cause and not due to willful
(a) Scope. This section provides rules for applying §1.385-3 to members of consolidated groups. Paragraph (b) of this section sets forth rules concerning the extent to which, solely for purposes of applying §1.385-3, members of a
computation under section 15) be treated—
(i) as beginning with the first day of the calendar month beginning nearest to the first day of such taxable year, or
(ii) as ending with the last day of the calendar month ending nearest to the last day of such taxable year,
as the case may be.
For purposes of the taxes imposed by this subtitle upon a DISC (as defined in section 992(a)), a DISC shall not be subject to the taxes imposed by this subtitle.
Editorial Notes
In the case of a subsequent sale or exchange by a transferee described in this paragraph, section 267(d) shall be applicable as if the loss were disallowed under section 267(a)(1). For purposes of
(i) whose principal residence (within the meaning of section 121) is on a farm,
(ii) who has a principal occupation of farming, or
(iii) who is a member of the family (within the meaning of section 461(k)(2)(E)) of a taxpayer
(a) General ruleEvery person who for the calendar year is an employer (as defined in section 3306(a)) shall—
(1) if the person is such an employer for the preceding calendar year (determined by only taking into account wages paid and employment during such preceding calendar year), compute the tax
(a) Scope and purpose. This section and §§1.1248(f)-2 and 1.1248(f)-3 provide rules under section 1248(f) that apply when a domestic corporation (domestic distributing corporation) distributes stock of a foreign corporation (foreign distributed corporation) in a distribution to which section 337, 355(c)(1), or 361(c)(1
meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day during the taxable year of such foreign corporation.
(b) Special rule for insuranceFor purposes only of taking into
Foreign Service Act of 1980,
(B) section 4 of the Central Intelligence Agency Act of 1949, as amended (50 U.S.C. 3505),
(C) title II of the Overseas Differentials and Allowances Act, or
(D) subsection (e) or (f
(a) Establishment of accountsThe Secretary shall maintain in the fund, in addition to any account which he maintains under section 9006(a), a separate account for the national committee of each major party and minor party. The Secretary shall deposit in each such account an amount equal to the amount which each such committee may
sale of distilled spirits (within the meaning of such term as it is used in section 5002(a)(8) for other than industrial use; and
(2) to require, of persons manufacturing, dealing in, or using any such containers, the submission to such inspection, the keeping of such records, and the filing of such reports as may be deemed by him reasonably necessary in connection
(1) amounts described in section 871(i)(3), if any interest thereon would not be subject to tax by reason of section 871(i)(1) were such interest received by the decedent at the time of his death,
(2) deposits with a foreign branch of a domestic
(a) General ruleExcept as otherwise provided in this section or in section 117 (relating to qualified scholarships), gross income includes amounts received as prizes and awards.
(b) Exception for certain prizes and awards transferred to charitiesGross income does not include amounts
(a) Application of taxThe tax imposed by section 1(e) shall apply to the taxable income of estates or of any kind of property held in trust, including—
(1) income accumulated in trust for the benefit of unborn or unascertained persons or persons with contingent interests, and income accumulated or held
(a) General ruleIn addition to the penalty imposed by section 7203 (relating to willful failure to file return, supply information, or pay tax), if any partnership required to file a return under section 6031, or a partnership adjustment
method is reasonable, and
(B) in all other cases, in accordance with regulations prescribed by the Secretary.
(2) Special rules
(A) Amortization of bond premiumIn the case of any bond (as defined in section 171(d)), the amount of bond premium, and the amortizable bond
(a) In general. A partnership may elect under this section an alternative to the payment by the partnership of an imputed underpayment determined under section 6225. In addition, a partnership making a valid election under paragraph (c) of this section is no longer liable for the imputed underpayment (as defined in §301.6241-1
(a) In generalNotwithstanding any other provision of this chapter (and under regulations prescribed to carry out this section), in any case where—
(1) an employer (or, if the employer is a partnership, each partner therein) is a member of a recognized religious sect or division thereof described in
(a) In generalAny person who shall—
(1) transport, possess, buy, sell, or transfer any distilled spirits unless the immediate container bears the type of closure or other device required by section 5301(d),
(2) with intent to defraud the United States, empty a